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By Rabbi Yitzchak Hanoka, Senior Rabbinic Coordinator at OK Kosher, and Educator at Kashrus: Be in the Know.

(The following is based on a Shiur given by Rabbi Hanoka for “Machon Smicha” [an online Smicha program under the leadership of Rabbi Shlomo Chaim Kesselman.] We are publishing it here for the benefit of the wider Jewish community, with their express permission. Our readers are encouraged to speak to their personal Rov for guidance as this article is for informational purposes only.)

Watch/Listen to the class:

Introduction

To understand the topic of vitamins and medication on Pesach, it’s important to understand the differences between fermentation, extraction, and synthetic processes. Medications are typically produced through fermentation or synthetic processes, where various chemicals are combined to create the desired product.

The inactive ingredients in medications, such as binders, can pose a general challenge as they may be lactose-based (dairy but not chametz) or a Pesach challenge if they are starch-based (when they are derived from wheat, however they are often derived from non-chametz sources like potato or corn). In some countries like Europe or Australia, wheat starch is more common. On rare occasions, the active ingredient itself, not just the binder, may be problematic.

Most vitamins are produced through fermentation, which changes the molecular profile of the ingredient. This is significant for Pesach because even if the end product is gluten-free, it may still pose a challenge. In contrast to the laws of pas Yisroel, where gluten-free products (that do not contain oats) are not considered “bread”[1], vitamins, however, even when produced through fermentation, may still originate from wheat sources, even if they are labeled gluten-free. Through fermentation, the gluten is converted into sugars, making it gluten-free from a legal perspective. However, halachically, if it originates from wheat starch, it may still be considered chametz [2].

To delve further into the fermentation process, raw materials are mixed with other ingredients and broken down to the point where the molecular profile of the raw material has changed. If the starting material, or feedstock, is wheat starch (although it’s usually not wheat starch, but more common in Europe or Australia), it is fermented into sugar, and then bacteria convert the sugar into the desired product. The final product will be labeled gluten-free, but it may still be problematic for Passover if the feedstock was wheat starch-based. Therefore, seeing ‘gluten-free’ on a vitamin product should not lead one to assume it did not originate from one of the five halachic grains – wheat, oat, spelt, rye, or barley.

Liquid Form

Another way of making vitamin products is through extraction. For example, when creating a liquid vitamin, raw materials are put into a solvent, like alcohol, to extract the desired compounds. This process doesn’t change the molecular profile, but simply transforms the material into a new form. To illustrate, vanilla extract is made by soaking vanilla beans in alcohol, which pulls out the flavor. The resulting extract has the same molecular profile as the original bean, just in a new form. For Passover, extracted products are easier to research since all ingredients, solvents, and extract materials are typically listed on the product label. This allows one to identify what needs to be researched, such as the type of alcohol used (e.g., cane, corn, or chometz-derived). By examining the product label, one can gain a clue about what requires further investigation.

As stated previously, in America, wheat starch is more expensive than cornstarch, and grain alcohol is more expensive than corn or sugar-derived alcohol. Therefore, in America, it’s less likely to be wheat derived.

Herbal Supplements

With regards to herbal supplements, the herbs themselves are not a problem, but the alcohol or glycerin used in the extraction process can be problematic. If the product is certified year-round by a Kashrus agency, then that’s the easiest and best way to verify the material, whether it’s only Kitniyos or whether there’s chometz. They would usually be able to provide you with that information, which is getting first-hand information, and that’s the best way to do that.

Tablets

When it comes to tablets, some of them are glazed, and the glaze itself can be an issue. In America, it’s typically kitniyos-based, but in Europe and Australia, it’s more common to use wheat-derived glazes. Additionally, vitamin C is often fermented from ingredients that are problematic for Passover. This is the background information on the food and vitamin industries.

In practical terms, what do we do with this information?

When a doctor prescribes medication for a physical, mental, or emotional ailment, it’s essential to take it as directed. We recommend that individuals take their medication in a swallowable pill form, as this is not considered eating. There is no question that individuals must continue taking their swallowable pills as medication on Passover if their doctor recommends that they do so.

However, chewable pills and liquid pills present a different scenario, as they are considered derech achila (the usual way of eating) and more problematic. In such cases, we recommend exploring alternatives in swallowable pill form, if possible. Most adults can swallow pills, but if someone has difficulty, they should consult with their doctor and Rav to find a solution.

My esteemed father-in-law, Rabbi DY Levy OBM, shared a poignant story about a Rav in Israel who knew someone who stopped taking medication due to chometz concerns, leading to a tragic outcome after Passover. Let us learn from this and ensure that those in our community take their medication to avoid any potential issues.

With regards to someone who’s illness is not life-threatening, not someone who the doctor says they must take medication, rather someone who feels unwell to the point that they have to be lying down to alleviate their symptoms – like someone with the flu, an ordinarily healthy person, they’re lying down to rest and recuperate, their life is not in danger. So even those who don’t eat kitniyos can be lenient here, because when the rabbis forbade kitniyos, they didn’t forbid it for small children and Cholim [3] (sick people). So, if someone feels so unwell they have to lie down, they’re comparable to a young child, then they’re allowed to take kitniyos for their health.

However, if someone’s feeling generally fine, able to go about their day, they’re able to function, just feeling a little bit unwell, maybe a little bit groggy, maybe their head’s a little stuffy, but they’re not needing to lie down to rest, then they’re not allowed to take kitniyos on Pesach, because they’re not really considered sick.

How do we ascertain whether something only contains kitniyos or has actual chometz?

To begin with, just by reading the labels of a product, is an insufficient method of determining what’s inside a product. For example: In the food industry, the FDA doesn’t require manufacturers to list ingredients that are going in, in less than two percent. Therefore, you can have an ingredient that’s higher than a 1/60th, (higher than 1.6 percent), but less than two percent that’s going in, that’s going to be real chometz, and you’re never going to know by reading the ingredient label.

To share a story, several years ago there was a kosher certified product, a soy-based drink, which was kitniyos but contained actual oat flour as a thickener, going in less than two percent but higher than 1.6 percent. The problem was that it wasn’t bottul  (nullified) and contained actual chometz.

That’s one thing to realize – just reading the ingredient panel isn’t enough to determine if a product is only kitniyos or contains actual chometz. The best approach is, if the product is kosher certified by a reliable agency, to call or email the rabbi in charge before Passover and ask if the product is chometz or only kitniyos. They can usually find out, having intimate knowledge of the factory’s processes and formula information, even if the product isn’t certified for Passover.

What about the lists that are available online, published by various people?

Rabbi Levy OBM was not fond of these lists because the lists are gleaned information usually from phone calls made to companies and you’re speaking to people on the telephone and you have to hope they’re giving you accurate information and you also have to hope that they understand what you’re saying, so there’s a heightened likelihood of uncertainty.  Of course, the people making this list deserve a lot of credit because they’re trying to help the community, but it’s important to understand that the list information is certainly not as accurate as information you have directly from the kashrus agency certifying the product and has direct information about the product.

So, if a person is in a situation where they must take a particular product, the list can only help because anyway halachically you are allowed to take it, so the list is good for that extra added level of comfort and protection.

How does halacha classify vitamins?

Simply put, if a person’s doctor recommends that they take vitamins daily to function, it has the status of medicine. They should take vitamins in swallowable pill form. However, even if they are taking kosher-certified vitamins, it’s still a good idea to reach out to the kashrus agency. They can often find an identical vitamin that only poses a kitniyos concern (not actual chometz) and has equal medicinal effect. To do this, one should first consult their doctor to determine if it’s a medicinal requirement. Then, they should go to their rabbi, who can contact the kashrus agency to obtain the necessary information.

If the product is not certified, if it’s a vitamin product not certified, and one absolutely must take it then it has the same category of medicine again swallowable pill form is the way to go and do as much research as possible. But again, do not chas vsholom endanger yourself by not listening to the doctor. You must listen to the doctor and do whatever the doctor says.

Stories and Conclusion

The following story is an illustration of this point. There was a very esteemed rabbi who was asked the question if someone is allowed to take medication on Shabbos.  We know it’s a rabbinic prohibition to take medication on Shabbos [4] because grinding up spices and things to make prepared medications, but if someone’s in the category of sick, they’re allowed to take it. The rabbi ruled in this person’s case that they were allowed to take medication on Shabbos. Someone questioned him and said, “You seem to be a little bit callous and a little bit lenient with regards to the halachos of Shabbos”.  He said, “No, I’m being strict in the laws of Pikuach Nefesh”.

There is an additional story about Rav Efrati from Eretz Yisrael. He was the personal assistant to Rav Elyashiv ZTZ”L. He once called up a particular Chassidishe Rav who was giving a Hechsher to certain vitamins and asked him if these vitamins, which were in swallowable pill form, were chometz or only kitniyos. The Rav told Rav Efrati that they’re just kitniyos.  He passed on the information to Rav Elyashiv who subsequently took the vitamins on Pesach.

He was 98 years old at the time, he was in the category of a Choleh who needed these vitamins to function, so he took them because that is the Halacha.

We see from gedolei Yisroel, that the proper approach is to follow what Halacha says in each situation without injecting fervor into things that are not rooted in Torah and Halacha.  This is achieved through the guidance from das Torah from one’s Rov.  The derech of Torah is to inject fervor into what Torah and Halacha instruct us to do, so we can inject fervor into our Torah and mitzvos observance.

[1] יו”ד סי’ קיב א’

[2] ראה יו”ד סי’ פ”ז י-יא’, או”ח שו”ע אדמו”ר או”ח סי’ תמ”ז ס”ג ותמ”ב י’

[3] ראה שו”ע אדמו”ר ס’ תנג ה’

[4] ראה שו”ע אדמו”ר ס’ שכ”ח א’

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